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Introduction

This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.

The General Data Protection Regulation (GDPR) seeks to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU. It should be noted that GDPR does not apply to information already in the public domain.

The NAPIT Group Limited and any of its subsidiary companies (hereinafter known as “The Group”) is pleased to provide the following Privacy Notice:

Personal Data

The Group uses the information collected from you to provide quotations, make telephone contact and to email you marketing information which The Group believes may be of interest to you and your business. In you making initial contact you consent to The Group maintaining a marketing dialogue with you until you either opt out (which you can do at any stage) or we decide to desist in promoting our services. The Group also acts on behalf of its clients in the capacity of data processor. When working exclusively as a data processor, The Group will be acting on the instruction of its client, and will work hard to ensure that the client is fully GDPR compliant.

Some personal data may be collected about you from the forms and surveys you complete, from records of our correspondence and phone calls and details of your visits to our website, including but not limited to, personally identifying information like Internet Protocol (IP) addresses. The Group may from time to time use such information to identify its visitors. The Group may also collect statistics about the behaviour of visitors to its website.

The Group’s websites use cookies, which is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Our Website uses cookies to help The Group identify and track visitors and their website access preferences. The Group’s website visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using any of The Group’s websites.

Any information The Group holds about you and your business encompasses all the details we hold about you and any sales transactions including any third-party information we have obtained about you from public sources and our own suppliers such as credit referencing agencies.

The Group will only collect the information needed so that it can provide you with marketing, consulting services or to fulfil a contract formed by any application or order, The Group does not sell or broker your data, although coincidentally there may be times when your information could be contained in data that The Group has purchased from a third-party list broker, on behalf of a client.

Legal basis for processing any personal data

To meet The Groups’ contractual obligations to clients and to also respond to marketing enquiries.

Legitimate interests pursued by The Group and/or its clients

To promote the marketing and consulting services offered by The Group and/or to market the services and/or products offered by The Groups’ existing clients.

Consent

Through agreeing to this privacy notice you are consenting to The Group processing your personal data for the purposes outlined. You can withdraw consent at any time by emailing [email protected] or writing to us, see last section for full contact details.

Disclosure

The Group may on occasions pass your Personal Information to third parties exclusively to process work on its behalf. The Group requires these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice and GDPR.

The Group does not broker or pass on information gained from your engagement without your consent. However, The Group may disclose your Personal Information to meet legal obligations, regulations, valid governmental requests or where it is required to do so to fulfil a contract. These disclosures may include Awarding Bodies, Central and Local Government, Enforcement bodies, Consumer Protection bodies, Other scheme operators, Other certification bodies, Scheme owners or Law enforcement agencies. Either of these third-parties may also enforce their own Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of The Group, its clients and/or the wider community.

Retention Policy

The Group will process personal data during the duration of any contract and will continue to store only the personal data needed for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purpose or as required by legal or regulatory obligations. When Personal Data is no longer needed, we either irreversibly anonymise the data (in which case we may further retain and use the anonymised information) or securely destroy the data.

Data storage

Data is held in the United Kingdom using different (multiple) servers. The Group does not store personal data outside the EEA.

Your rights as a data subject

At any point whilst The Group is in possession of or processing your personal data, all data subjects have the following rights:

Right of access – you have the right to request a copy of the information that we hold about you.

Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.

Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.

Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.

Right of portability – you have the right to have the data we hold about you transferred to another organisation.

Right to object – you have the right to object to certain types of processing such as direct marketing.

Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.

In the event that The Group refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.The Group, at your request, can confirm what information it holds about you and how it is processed.

You can request the following information:

Identity and the contact details of the person or organisation (The Group) that has determined how and why to process your data.

Contact details of the Data Protection Officer, where applicable.

The purpose of the processing as well as the legal basis for processing.

If the processing is based on the legitimate interests of The Group or a third party such as one of its clients, information about those interests.

The categories of personal data collected, stored and processed.

Recipient(s) or categories of recipients that the data is/will be disclosed to.

How long the data will be stored.

Details of your rights to correct, erase, restrict or object to such processing.

Information about your right to withdraw consent at any time.

How to lodge a complaint with the supervisory authority (Data Protection Regulator).

Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.

The source of personal data if it wasn’t collected directly from you.

Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

To access what personal data is held, identification will be required

Complaints

In the event that you wish to make a compliant about how your personal data is being processed by The Group or its partners, you have the right to complain to The Groups’ CEO. If you do not get a response within 30 days you can complain to the Data Protection Regulator.